Estonian Gambling Licence and the FIU Contact Person (Compliance Officer): What Every Operator Needs to Know
If your company holds an Estonian gambling activity licence, or is applying for one, you are an obliged entity under Estonian anti-money laundering law.
One of the obligations that comes with it is the appointment of a qualified FIU Contact Person who works permanently in Estonia and is approved by the Estonian Financial Intelligence Unit (FIU). The role is also called compliance officer in the official English translation of Estonian law, and is close to what international iGaming practice calls the MLRO (Money Laundering Reporting Officer).
Complium provides qualified contact persons in Estonia, so you can stay compliant without building a local compliance function from scratch.
A Note on Terminology: Contact Person, Compliance Officer, and MLRO
In the Estonian version of the Money Laundering and Terrorist Financing Prevention Act (Rahapesu ja terrorismi rahastamise tõkestamise seadus, MLTFPA), the function is called the “kontaktisik”, literally contact person. In the official English translation published on Riigi Teataja (the Estonian State Gazette), section 17 uses “compliance officer” for the same function.
Both terms describe the same role. In international iGaming practice the closest equivalent is the MLRO. Many operators already have a group MLRO in Malta or elsewhere who runs the AML programme. That person can stay in place, but usually cannot be the Estonian contact person, because the contact person must work permanently in Estonia.
Legal references: MLTFPA (Estonian text, latest consolidated version): https://www.riigiteataja.ee/akt/113022026013?leiaKehtiv | Official English translation: https://www.riigiteataja.ee/en/eli/ee/517112017003/consolide/current
The Legal Framework: Why a Contact Person Is Required
Gambling operators licensed in Estonia operate under two regulatory frameworks. The Estonian Tax and Customs Board (EMTA) oversees gambling licensing and operational compliance under the Gambling Act (Hasartmänguseadus, HasMS). The FIU (Rahapesu Andmebüroo) supervises compliance with AML/CFT obligations under the MLTFPA.
As a holder of an Estonian gambling activity licence, your company is an obliged entity under MLTFPA section 2(1)(3). The Estonian AML/CFT obligations apply to your business regardless of where your company is incorporated or where your operational team is based.
Since 1 January 2026, the Gambling Act requires every gambling operator to have a contact person appointed and approved by the FIU. EMTA submits each licence application to the FIU, which decides within 60 days and refuses approval if the applicant does not meet MLTFPA section 17(2) and (5)-(9) or the documentation requirements of section 70(3) and (3¹) (HasMS section 18(3¹) and (3²)). Operators licensed before 2026 have a transition period until 1 January 2027 to bring their contact person into line (HasMS section 102(5)). After that date, non-compliance is a ground for revocation of the licence (section 102(8)).
MLTFPA section 17: who can be the contact person
- The contact person is appointed by the management board and reports directly to it (section 17(2)).
- The duties are performed by an employee or a structural unit of the operator (section 17(4)).
- Only a person who works permanently in Estonia and has the education, professional suitability, abilities, personal qualities and experience needed for the role, and an impeccable reputation, may be appointed. The appointment is approved by the FIU (section 17(5)).
- To assess suitability, the FIU may obtain information from the candidate, the employer and state databases (section 17(6)).
In practice this means a person who lives and works in Estonia, has prior AML experience, and is employed by the operator with the employment entered in the Estonian employment register (TÖR). The FIU by market practice also conducts an interview with the candidate.
A Practical Challenge for Non-Estonian Operators
Estonia’s Gambling Act permits companies incorporated in other EU/EEA member states to hold an Estonian gambling activity licence directly, without setting up an Estonian entity. A significant share of licence holders are incorporated in Malta or elsewhere and have no Estonian presence at all.
For these operators the AML team and group MLRO are based outside Estonia, and so is legal counsel. But the FIU writes in Estonian and expects a response in Estonian, from a contact person who works in Estonia. Finding, employing and retaining that person from abroad is the hard part.
Key Practical Risk: The FIU sets short deadlines for its information requests and has fined gambling operators that failed to respond on time. A language barrier is not an accepted excuse.
Who Needs an FIU Contact Person?
Every company holding, or applying for, an Estonian gambling activity licence issued by EMTA. This includes operators holding licences for:
- Games of chance (online casino, poker tournaments), minimum share capital EUR 1,000,000
- Toto / sports betting, minimum share capital EUR 130,000
- Games of skill with monetary prizes
The current list of licensed gambling operators in Estonia is publicly available on the EMTA website. For new applicants, the contact person needs to be in place at the application stage.
What the Law Says the Contact Person Must Do
Section 17 of the MLTFPA sets out the duties of the contact person. The core obligations are as follows:
1. Organise the prevention of money laundering and terrorist financing within the company.
The contact person is responsible for ensuring the company has functioning AML/CFT arrangements in place. This does not mean they personally run the compliance programme. They oversee that the obligation is being met and escalate where it is not.
2. Act as the company’s contact person with the FIU (Rahapesu Andmebüroo).
The contact person is the formal point of contact between the company and the FIU. Official FIU correspondence is directed to and handled by this person, in Estonian.
3. Collect and analyse information on unusual transactions or circumstances arising from the company’s activities.
Where the company’s internal AML team identifies unusual or potentially suspicious activity, that information flows to the contact person, who assesses it and decides, together with the internal team, whether FIU reporting is warranted.
4. Transmit information to the FIU on suspicion of money laundering or terrorist financing.
This is the core reporting function: filing suspicious transaction reports (STRs) and international sanctions reports (ISRs) with the FIU via the RABIS reporting portal. The contact person reviews the completeness of reports prepared by the internal team and submits them to the FIU. The MLTFPA imposes strict deadlines on these submissions.
5. Fulfil all other obligations of the contact person arising from the MLTFPA.
This includes responding to FIU requests for information, cooperating with supervisory inspections, and monitoring developments in Estonian AML/CFT law and FIU guidance that may affect the company.
The contact person must work permanently in Estonia and possess the qualifications, experience and impeccable reputation required under MLTFPA section 17(5). The appointment must be approved by the FIU and any change of contact person notified to it.
Complium’s FIU Contact Person Service
Complium provides qualified FIU contact persons (kontaktisik / compliance officer) for licensed gambling operators. We have experienced AML professionals in Estonia, most of them from the compliance teams of banks and other regulated firms, who take on the role part-time. The contact person is employed by your company, as the law expects. Your substantive AML/CFT obligations remain with your own team.
What is included
- Qualified Estonian-resident FIU contact person / compliance officer, available for FIU appointment
- Receipt and forwarding of all FIU correspondence in Estonian/English
- Coordination of STR and ISR filings with your internal AML team and submission to the FIU via RABIS
- Monitoring of MLTFPA, ISA, and FIU guidance developments with regular updates to your team
- Backup and substitute coverage in cases of unavailability
- Registration in the employment register (TÖR) available as an optional service
Why Act Now
The FIU’s suitability assessment takes time, and what counts is the approved appointment, not the date of filing. Operators that still have a non-resident or unapproved contact person are better off arranging the change on their own terms than in response to a regulatory inquiry.
Contact Complium
Reach out to discuss your situation and receive a service proposal tailored to your licence type and operational structure.
Legal References
Money Laundering and Terrorist Financing Prevention Act (MLTFPA): section 2(1)(3) definition of obliged entities; section 17(2) and (4)-(6) appointment, qualifications and FIU approval of the contact person; section 70(3) and (3¹) documents submitted with a licence application.
Estonian text (latest consolidated version): https://www.riigiteataja.ee/akt/113022026013?leiaKehtiv
Official English translation: https://www.riigiteataja.ee/en/eli/ee/517112017003/consolide/current
Gambling Act (Hasartmänguseadus, HasMS): section 17(1) licence requirements; section 18(3¹) and (3²) FIU approval of licence applications; section 102(5) and (8) transition period and consequence of non-compliance. Estonian text: https://www.riigiteataja.ee/akt/130122025009
FIU notice on appointing and approving a contact person: https://fiu.ee/uudised/uuendatud-videokoolitus-kontaktisiku-maaramisest-ja-kooskolastamisest
International Sanctions Act (Rahvusvaheliste sanktsioonide seadus): parallel reporting obligations applicable to licensed operators.
EMTA list of licensed gambling operators: https://www.emta.ee/en/business-client/registration-business/gambling-operators/list-legal-gambling-operators
This article is provided for informational purposes only and does not constitute legal advice.
